Dealstruck’s Response to the Treasury RFI

The Treasury Department has extended the comment deadline on the Marketplace Lending Request for Information until September 30th. In the meantime, one well known lender, Dealstruck, has already submitted their response. A few excerpts of their comments are below, but you can view their response in its entirety here.

​We encourage the Treasury to weigh stated use of proceeds and debt service coverage ratio heavily when considering factors important in extending credit for alternative online lenders.

We have no opinion or recommendation as to whether lenders should have skin in the game. If there is a seller and a buyer for an asset, a market exists, and the United States promotes open markets. At Dealstruck, we have chosen to take balance sheet risk because it helps us to position ourselves for a longer-term sustainable model across economic cycles, and allows us more flexibility in riding out potential future economic downturns.

we believe that the best way for banks to participate in the alternative online lending space is to offer financing to the innovative lenders, rather than attempt to change underwriting procedures and processes to facilitate smaller, riskier loans themselves

The federal government can also take a substantial role in leveling the regulatory playing field in pricing and access to SMB capital. Each state has substantially different regulations over commercial transactions, including lender licensing and usury caps. This has created perverse and unintended consequences, hampering both small businesses and transparent lenders